Tae M. & Young J. Kim - Page 2

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          $8,411 and $1,682, respectively.                                            
               The issues remaining for decision for the year at issue are:           
               (1) Do petitioners have certain compensation income with               
          respect to the exercise of certain stock options granted under an           
          employee stock purchase plan?  We hold that they do.                        
               (2) Do petitioners have certain claimed long-term capital              
          losses?  We hold that they do not.                                          
               (3) Do petitioners have certain interest income from the               
          United States Department of the Treasury?  We hold that they do.            
               (4) Do petitioners have certain income from the sale of                
          certain stock?  We hold that they do.                                       
               (5) Did petitioners fail to include in the total interest              
          income reported in their tax return certain interest from Wash-             
          ington Savings Bank?  We hold that they did not.                            
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
               At the time petitioners filed the petition in this case,               
          they resided in Bowie, Maryland.                                            
               During 2002, petitioner Young J. Kim (Ms. Kim) was employed            
          by Fannie Mae as a systems analyst.  At a time not disclosed by             
          the record before January 17, 2002, Fannie Mae granted Ms. Kim              
          certain options to buy Fannie Mae stock under an employee stock             
          purchase plan (Fannie Mae ESPP).  Each option under that plan had           
          an exercise price of $66 per share.                                         






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